Familicide, or Family Annihilator, is never easy or simple cases. Often they are sad, horrific, and involve small children. I guess I will never understand why a child must be killed. I can think of no reason whatsoever. In any case, this is a particularly sad case of the Carnation Murders, when a Carnation is not a flower.
- Before the Family Annihilator Murders, The Anderson Family
- Wayne and Judy, Michele Anderson’s Mom and Dad
- Mary Anderson, daughter, and sister of michele Anderson
- Michele Anderson and Joseph McEnroe, daughter and boyfriend
- What Happens when two sociopaths meet?
- Joseph McEnroe and Michele Anderson — Moving in with the “Parents”
- Moving toward Christmas
- Christmas Eve in Carnation
- Waiting for Scott and Erica
- The time of the murder of Scott, Erica, and the children
- CRIME SCENE RECONSTRUCTION
- What happened Next
- The investigation of Joseph McEnroe and Michele Anderson
- Confession Time in Carnation
- What Happened between 2007 and 2015
- The Trials, Finally
- Reprise of Mary Anderson
- The sentences
- The aftermath
The Family Annihilator murders occurred on a crisp Christmas eve in 2007 in Carnation, Washington. Six people were killed in a case of familicide. This is the true story of Joseph McEnroe and Michele Anderson.
Familicide, or Family Annihilator, is broadly defined as one family member killing multiple other family members, where the goal is to destroy the family unit (Malmquist, 1980, p. 298). As a whole, familicide is relatively rare in comparison with other forms of crime. The most common form of familicide is the murder of at least one child and a spouse/ex-spouse/intimate partner (Liem, Levin, Holland, & Fox, 2013, p. 351; Wilson, Daly, & Daniele, 1995, p. 275). These events are considered a type of mass murder as multiple people are killed in a short period of time in one setting (Fox & Levin, 2013, p. 47). The two components of familicide are uxoricide, or the killing of one’s wife, and filicide, the killing of children by their parents (Wilson et al., 1995, p. 276).
Family Annihilators: The Psychological Profiles of Murderous Fathers An honors thesis presented to the School of Criminal Justice, University at Albany, State University of New York in partial fulfillment of the requirements for graduation with Honors in Criminal Justice and graduation from The Honors College
Research Advisor:Alan Lizotte, Ph.Dr
Wayne and Judy Anderson, both 61, Scott and Erica Anderson, both 32, and their two children Olivia, age 5, and Nathan, age 3, were all murdered that night. The case hereafter was called the “Carnation Murders” due to the murders occurring in Carnation, Washington. But to believe what happened, you have to start way before the murders.
Before the Family Annihilator Murders, The Anderson Family
The Anderson Family appeared to be complicated. Jealousy raged rampant from Michele Anderson, jealous of Erica, Scott’s wife, mostly, and jealous of Mary, just for being Mary. It has been said numerous times that “What Michele wants, Michele gets, or all hell breaks loose.” Here’s a look at the basic Family Tree. You’ll notice that Joseph McEnroe is shown as well, as he is an intricate part of the story.
Wayne and Judy, Michele Anderson’s Mom and Dad
Wayne and Judy Anderson loved their family. They always looked forward to the big Christmas Eve celebration with their two daughters, one son, and their families. With children ranging from Mary (41), Scott (32), and Michele (age 29 at the time of the crime), the Anderson’s have a full life. Wayne and Judy live on 11 acres with plenty of room for Michele Anderson and her boyfriend, Joseph McEnroe, to live in a trailer on the property.
Wayne is retired and Judy works at the post office, delivering mail. Both are extremely popular and well-liked in the small community of Carnation, Washington.
Scott and Erica, son and daughter-in-law.
Scott is married to Erica and they have two children, Nathan, 3, and Olivia, 5. They live only 25 minutes away in Black Diamond, WA. All in all, it appeared to be a close-knit family all snuggled together in a 25-mile stretch.
Mary Anderson, daughter, and sister of michele Anderson
Mary Anderson was from a previous relationship that Judy had, When Judy married Joe, he adopted Mary. Mary was a big part of the family but appears to live with her son in Black Diamond, WA, about 25 miles away. Not much is written about Mary’s life, other than the fact that on the day of the murders, Mary was supposed to also attend the Christmas Eve dinner. However, her son had a cold and Mary felt it was best to abstain.
Michele Anderson and Joseph McEnroe, daughter and boyfriend
Both Michele Anderson and Joseph McEnroe were 29 years old at the time of the murders. As the story goes, being the youngest or just because of behavior, the reason is unknown, but everything tended to revolve around Michele. In true Sociopathic fashion, what Michele wanted, she got. If she didn’t there was hell to pay.
Neighbors have reported of Michele’s outbursts over basically nothing. Her behavior started as timid, shy, even reclusive. In time, it became belligerent, and outright mean. It is unknown what, if anything, happened to make Michele change her behavior. Supposition would say that it began around the time of her brother’s marriage to Erica and worsened with the relationship with Joseph.
What Happens when two sociopaths meet?
“Imagine — if you can — not having a conscience, none at all, no feelings of guilt or remorse no matter what you do, no limiting sense of concern for the well-being of strangers, friends, or even family members. Imagine no struggles with shame, not a single one in your whole life, no matter what kind of selfish, lazy, harmful, or immoral action you had taken … You can do anything at all, and still your strange advantage over the majority of people, who are kept in line by their consciences, will most likely remain undiscovered. How will you live your life? What will you do with your huge and secret advantage?”
Martha Stout, The sociopath next door
The story Of Michele and Joseph would be funny and tragic, if not for the circumstance of the murders. You see, they met online. Now, I have no objection to people meeting online. Some of my best friends met that way and even married. But in this case, you’ll have to judge for yourself.
As the story goes, Michele only put a photo of her eyes as her profile picture. She has very pretty eyes, she thought. She and Joseph met in an online fantasy fiction chatroom and started chatting. We learn later that he thought the Michele he was going to meet was a “different Michele” that he had been chatting with.
In his testimony, McEnroe stated,
“She came across very sweet. Very cute. She sent me some old pictures. I sent her a camera. The pictures she sent showed her being pretty athletic.”
McEnroe indicated they chatted online for six months before he mailed his belongings to Washington to be with Anderson.
Say what? Yeah, after six months, sight unseen, he simply mailed everything he owned to Carnation, Washington, from Fayetteville, NC, to be with her.
He further stated, “She described herself as Linda Hamilton in ‘Terminator 2,’ muscular but trim. She wasn’t particularly muscular; she was kind of big. I was taken aback and surprised.” McEnroe decided to disregard it because “I came out of here for love, but not because of the size she is.”
Wow. I guess that’s love, huh. Hmm.
For further descriptions of Sociopaths and Psychopaths, and other terms, see our dictionary at Criminal Justice Definitions and Terms.
Listening directly to the testimony of Joseph McEnroe is challenging. It seems Joe has a speech impediment, using “w” for “r”, etc, and is very soft-spoken. That in and of itself, of course, isn’t a reason or rationale for murder. My question is could it be, due to this impediment, that some of his testimony could be misunderstood?
I can tell you, no. It isn’t. Although difficult at times to read and hear, his words were very plain when it came to his testimony, especially about Erica and the kids. I now firmly believe this was all an act on Joseph’s part. His soft-spoken manner made him appear to be more pliable and enthralled with Michele. That is not true. He is a Sociopath, plain and simple. Don’t misunderstand, Michele is just as bad.
During Joe’s testimony, it was perceived by me that he was simply talking to a friend. His tone was open, sharing, and even comical (or tried to be). To be honest, the whole testimony made me sick.
There is confusion about the amount of the “loan” Michele gave to Scott. Michele indicates in all her testimony that it was $40,000. Now, I submit where the hell did she get the $40k in the first place? According to testimony from Joseph, it was more like $3,000 that she gave Scott to fix a motor in a 20-year-old IROC. The car never got fixed. Michele used this as an excuse to kill the family. The $40k just made it sound better. There is no evidence, either in her bank records or otherwise, that the $40k ever existed.
According to Joseph, Michele tried to get Scott to help with the car several times. She got tired of waiting. It reminds me of “What Michele wants…”. Her personality would definitely rise to having her own time frame. Joseph indicated that no one was interested in working on the car because it was so old.
Michele Anderson tried to get her parents to help “make” Scott do something. Her father, Wayne, indicated that she and Joseph had been living rent-free in the trailer for over a year. It was time Michele and Joseph did something on their own. At this point, neither were working. They were “working on the trailer to make it livable”. Having her parents say it was time to move out absolutely enraged Michele.
At that time, they had a little money, but Michele wasn’t interested in moving, that she was entitled to the property and she would get cut out of the will if they moved. There’s that sense of entitlement again.
Michele’s parents drew up a rent contract that further enraged Michele. There is no evidence that the contract was ever signed or enforced.
Michele was obsessed with the idea that killing the family would help overcome past wrongs, according to Joseph’s testimony. She felt the children would be warped if they weren’t also killed.
Joseph McEnroe and Michele Anderson — Moving in with the “Parents”
Michele and Joseph lived in South King County, then moved to Fall City in 2004 and rented a mobile home there until late 2006. At first, both Michele and Joseph were working. Joseph worked for Target. Michele worked as a night security guard at Nintendo. We are not exactly sure what happened, but late in 2006, Michele lost her job. They then moved into Anderson’s trailer on the main property. McEnroe kept his target job for a time, but then, according to McEnroe, he quit when Michele told him to.
So around Christmas time in 2007, both Michele and Joseph were unemployed and still living rent-free in the trailer down the road. According to Mary, Judy had enough. Judy told Michele she would have to pay rent or move out. Judy had hoped that the threat would motivate the two to get jobs or something. Instead, it further enraged Michele.
According to Joseph, he tried “everything” to stop this.
Moving toward Christmas
On Christmas Eve, 2007, as was typical in Carnation, Washington, Wayne and Judy’s home was decorated in all the traditional Christmas spirit, and a roast was cooking in the oven. Judy loved to decorate and their home was a welcoming sight.
The plan was for the entire Anderson Family to attend the Christmas Eve dinner, as was traditional, around 5. The first to arrive was Michele and Joseph at around 2.
Nothing would ever be the same again.
Christmas Eve in Carnation
Michele and Joseph arrived first, with Scott, Erica and the kids scheduled to arrive around 4 pm. The story is fairly consistent between the confessions of both Michele and Joseph.
Joseph indicated in his testimony, that he was not expecting to survive this. So he made extra effort to shower, change his clothes, and mental preparation to die. Then he indicated he was only supposed to be the backup. My question is, if he was only supposed to be the backup, why did he not expect to survive it?
He was only there to make sure Michele was safe. This makes no sense to me. Michele had 15 bullets, he had 6 and some in his pockets. Protection? Bullshit. Joseph indicated he was trying not to think about what was really going to happen.
Joseph indicated that “the 9 mm clip had been loaded for a while and that’s why it probably jammed when it did. It wears out the spring.” He chambered a round for Michele. Joseph carried a box as a decoy.
Paraphrasing, here is the story.
Michele and Joseph arrive. Joseph indicates that he sat with Wayne for about half an hour watching TV. Michele was in the kitchen with Judy making a green bean casserole and helping her Mother. Both have guns on them hidden.
Wayne indicated that Michele and Joseph may want to move their truck because Scott was coming soon. Joseph went to Michele and took her aside and said “if we are going to be moving the truck, if you are going to do this, let’s do this, if not let’s go.” Joseph indicated they could just walk away. Michele stated to Joseph that they couldn’t just walk away now…that the parents were already suspicious.
At that time, Wayne is in the living room, relaxing; Judy in the Craft Room, wrapping presents. Joseph goes to the Craft Room and talks to Judy while she is wrapping presents. Michele approaches Wayne.
Joseph and Judy heard “What the hell” and a gunshot. Michele is standing at the back of the couch about the middle of the cushion. He turns around and sees Michele with the gun and says “What the hell”. Michele shoots and it goes out the window.
I envision Michele approaching her father and letting him know that she felt slighted in whatever way she could come up with at the moment. I’m sure Wayne tried to placate her, maybe ‘Now Michele, calm down.’ or something to that effect.
Pissed off royally, Michele pulls the gun and points it at her Dad. I can only imagine the thoughts that went through Wayne’s mind as he sees his beloved daughter standing in front of him with a 9mm pistol pointed at him. She pulls the trigger and misses. The bullet goes through a window and the shell casing is never found. Is it possible that Michele really didn’t want to kill her father? Nah. She’s a sociopath. She feels nothing
Then, the gun jammed. So now Michele is yelling at Joseph to help her and I’m SURE Judy hearing the shots, runs to her husband. In a very short span of time, which I have to admit, while writing this, seems like a long time, Joseph went into the kitchen and through the hallway. Wayne started up from the couch. Joseph went into the living room. Judy is between Joseph and Michele at this point. Michele steps into the kitchen.
Wayne is charging toward them. Joseph pulls his gun and fires at Wayne. Wayne falls, then Joe shoots him in the head.
Judy ran back to the kitchen and tried to hide. Joseph found her and shot her twice. Once in the head. According to Joseph’s testimony, the last thing Judy said was “NO!”. Then, he apologized to her.
Yes, I said ‘apologized to her’. Joseph McEnroe is a Creep.
Narcissistic behavior. We weren’t there, so this is supposition. In my opinion, he wanted the court and media to think he was human. For all we know it could have been said in a sarcastic manner. I’m fairly convinced that Joseph McEnroe was a true Psychopath with Narcissistic tendencies. Michele? I’m not sure yet.
Waiting for Scott and Erica
Erica and Scott were due to arrive in about an hour and a half or so. Michele and Joseph decided that Mom and Dad had to be moved.
First, they grabbed Wayne and drug him outside toward the shed. He was too heavy to pick up and over the doorway of the shed, so they dumped him outside and found an old astroturf-type rug and draped it over him in an effort to hide him.
Now both Wayne and Judy are dead and there is a mess to clean up. At this point, I can imagine the conversation being matter of fact. After all, they both have antisocial personalities of some sort, so there is no emotion involved. So one of them decided it had to be cleaned up.
Joseph said he put a bag over Judy’s head because he “couldn’t look at her because of the emptiness where she should be”. Joseph breaks down. I didn’t see any tears, but it appeared he was upset. He kept repeating that he was protecting Michele
After the killing, Joseph asked where to put Judy. Michele indicated to put her in the shed. Joseph said he had to use the carpets he had fallen on to move Wayne. He is having a hard time because Wayne is so heavy. Michele keeps running off.
Eventually, she came out to help move Wayne to the shed. When they moved him his shorts and pants came down. Joseph indicated he hadn’t touched any skin. They cannot get Wayne in the shed. Joseph appeared to think this was “gross” in some way.
It should be noted that when Wayne was found, he had on white socks that had no dirt or debris on the bottom, indicating he did not walk to the shed on his own, obviously. His pants and underwear were also pulled down to his ankles, according to one source. IF this is true, I guess it could have happened when they drug him? Or, in my opinion,
Michele had a hand in this as a last act of denigration to her father. What was really interesting was the boot print they found… on his torso… that matched Michele’s boots. I can’t imagine having that kind of rage. How sad. She’s not JUST a family annihilator, she’s also cruel.
But back to the cleanup, next was Judy. Being a small individual, they were able to pick up Judy and basically carry her to the inside of the shed, among the BBQ grills, old chairs, and the like. They simply dumped her there, as a discarded piece of lawn furniture. Judy deserved better than this.
Next was all the blood that had to be cleaned up. Michele and Joseph went back and forth to their trailer to get rags, towels, rugs, and the like to use while cleaning up all the blood. Once the items were of no more use, that item went back to the trailer’s fire pit to be burned. It was a lot of work, I’m sure. Joseph further stated that they washed some of the towels. Sorry, I just can’t imagine using one of those towels ever again, even if they had been bleached.
Joseph keeps emphasizing that at this point his mind was breaking. That he felt like someone else was doing these things and he was just watching. That part of his consciousness had split off, that it was the void. Joseph just kept rambling.
According to the crime scene folks, they were fairly successful in cleaning up the environment from a surface point of view. Next, they wait.
The time of the murder of Scott, Erica, and the children
Joseph indicated to Michele that he was done, that he didn’t want to kill anyone else. Michele told him he didn’t have to. That she’d take care of it.
Joseph and Michele had a discussion about the children. It was decided that “they were already corrupted, that if that weren’t already, they would be by this. So “the only decent thing to do would be to free them so they would not have to live through this tortured existence”. Classic family annihilator. Other similar cases were John List, Chris Watts, and others.
By the time Scott, Erica, and the children arrived, Joseph indicated the air was smoky and still smelled of blood. Joseph and Michele simply acted like everything was normal. Joseph tried to say there was no real plan, but the prosecutor disagreed.
CRIME SCENE RECONSTRUCTION
The prosecution had a true scale replica of the actual crime scene replicated, down to recreation of the floor and blood stains.
Erica was sitting on the loveseat on the left side toward the middle. Scott sits down on the right side of the loveseat. Joseph sits down in the recliner. The children are to the sides of Erica. Joseph starts making conversation with Scott about his latest project.
Michele was still standing on the opposite side of the coffee table and the couch. She had the revolver hidden in her sweatshirt. Michele asks Scott “Where’s my Money”.
Scott looked very upset. Scott told her he didn’t know what he was talking about. She starts firing at him. The bullet hit him under his chin. Scott started charging at her, she fired again and the shot went into his abdominal wall. She twisted around and dropped down with her legs up drawn up against her chest, cradling the gun. Scott wrapped around her from behind, kneeling.
Joseph started freaking out, and he tried to get the gun from Michele but she wasn’t letting it go, so he tried to pull Scott off, but he couldn’t because Scott was too big. He asked Michele where the gun was. Michele said it was on the table beside Wayne’s bed, but it wasn’t their gun. It was a .32 and Joseph felt that Scott had already been shop with a .357 so a .32 wasn’t going to help. He asked where the “9” was, Michele said it was in the kitchen cabinets.
Joseph went and got it and there was a bullet that was jammed. He unjammed the gun, set the gun and he fired toward Scott, but he hit the TV instead. Scott fell back and didn’t move again, finally succumbing to his injuries.
At one point, Erica got the phone and called 911. Joseph took the phone from her and pulled out the battery and put it aside. Erica went to where she was previously. Joseph reloaded at this point. Michele fired several times on Erica. It is uncertain whether the 911 call was before or after she had been shot; there are two versions told.
She was trying to protect her children. At this point, both Erica and Olivia had been hit. Erica begged Joseph, “We love you, you don’t have to do this.”
Joseph apologized to Erica, then “I shot her first, so she didn’t have to watch her children die.” Joseph said. Next, he shot Nathan because he was closest to him. Joseph said that Nathan, after being shot, “He held up the phone batteries and showed it to me.” Joseph took this to mean that Nathan was accepting what was about to happen. Then he “finished off” Olivia.
Judging by the use of words, Joseph felt no remorse for what happened. The mere statement that he “finished off” Olivia is enough to convince me of that.
Joseph said he was trying to come up with a reason not to kill himself. He didn’t feel like he was done yet. But it wasn’t that he wasn’t done with killing.
Joseph and Michele left as soon as possible. Michele closed and locked the gate near the entrance to the property.
What happened Next
The 911 operator answered the 911 call from Erica. She could hear noise and what “sounded like a party or something”. In any case, she dispatched the local police.
The police got to the property. Everything was closed up. The gate was closed and locked. The police didn’t feel they had probable cause to enter the gate. There were no noises or sounds of a party going on, so they left.
Judy didn’t show up for work. Judy’s best friend, Linda Thiele, thought it very strange. Judy had never been late or absent without a call. After two days, Concerned, Linda went to their house.
When she arrived, the gate was closed and locked, which was odd, but easy to get around, you just couldn’t drive up to the property. It was probably .25 miles to the house itself. Linda reached the house and found the front door unlocked. When she opened the door and called for Judy, she saw what appeared to be a man’s shirt lying on the floor with blood around it. She immediately backed out of the house and called 911.
Once cops arrived after the 911 call from Linda Thiele and opened the door…it was open… they inferred that it had to be someone they knew.
There was much speculation about the original officers not going through the gate and finding the crime scene. It was determined that all were deceased prior to police original arrival, pretty shoddy police work. could have prevented the shock of a friend arriving and seeing the bodies.
In any case, there was a discussion between Joseph and Michele about where to go. They ended up going East instead of West, coming back to the Trailer several times. Eventually, they appear back on the property around the time the Police were there discovering the bodies.
The investigation of Joseph McEnroe and Michele Anderson
Once officers arrived and opened the door (it was unlocked), they found the body of Scott Anderson. Right next to the soft was the body of his wife, Erica, and their two children. It appeared as if Erica was trying to shield the children. All were deceased.
The officers continued their search and discovered Wayne’s body on the path to the shed. Inside the shed was Judy. The scene was horrific.
Michele and Joseph show up. The Detective thought he was giving a death notification, then everything changed.
Confession Time in Carnation
You can hear their actual confessions on YouTube:
After the confessions, the defendants were arrested and taken to jail for processing.
What Happened between 2007 and 2015
For eight years, justice was slow to be delivered. Both defendants filed many, many motions, some frivolous, some standard motions.
There were many twists and turns, that will be discussed in another post.
One such twist concerned one of the defense counsels for Michele receive charges of ethical violations for stealing material from the crime scene!
Anyway, it took 8 years to get to the trial part of this over-whelming case.
It should be noted that Michele demanded that the Judge allow her release on her own recogni-zance to be able to hire her own attorney to her liking.
She called it “furloughed”.
The Judge, of course, said nope.
This particular item was part of the appellate case, which was also denied. More details on that in another post as well.
The Trials, Finally
Joseph McEnroe was found guilty. The jury could not agree on the death penalty, which is an automatic sentence of life without the possibility of parole.
Michele Anderson was also found guilty, but not without a show. Right before closing arguments, Michele asked to be “furloughed” to choose her own attorney. She accused the Judge of being partial, and a number of other things.
Reprise of Mary Anderson
Mary also testified about her sister, Michele Anderson. Court transcripts indicate Mary said that Michele was a spoiled brat.
During her testimony, she stated:
“We were coming back from Monroe a couple months prior. All of the (sic) sudden, Michele flipped out. She started saying that she hated mom and date and she really hated Scott. She said she wanted to kill them. That’s how angry she was.”
Mary also stated that she had talked with Judy about the conversation and that both she and Judy didn’t take it seriously.
Both defendants were sentenced to six sentences of life without parole, ensuring they will never be released.
During the sentencing, Mary Anderson testified at the sentencing hearing for Michele Anderson. Her testimony, gathered from Court Transcripts, is as follows:
Mary is devastated about losing her entire family. At the sentencing hearing for Michele, she stated
“Oh, Michele, I want you to know that we loved you so much. You know the truth and you destroyed me. And look what you have done to your life. Do you care what you did to our family? Your brother loved you so much. You’ll have a lot of time to think about that. I loved you so much. I suggest that one day, you learn about our Lord Jesus Christ because we all go. I don’t know where you’re going to go but I know where I’m going to go. And I’ll be with them so you think about it, okay? Just know that they loved you. Please? Thank you.”
Mary Anderson at Sentencing of Michele anderson
There is never a family annihilator case that the family felt justice has been served completely and then family moves on. The aftermath is devastating.
Imagine, Mary Anderson is the only surviving member of the family, other than the killer. Her life, and her son’s are forever changed.
The reason I have written about this case, in particular, is because of the family annihilator aspect, or familicide. However, I will NEVER understand the killing of children. There was absolutely no reason to kill those children.
So what did we learn? We learned that two sociopaths together are very dangerous, feeding on each other, and can become violent even if one isn’t necessarily violent. We still have several questions for which we don’t have answers.
- Would it have truly made any difference had the police officers went around the gate to check the house after Erica’s 911 call?
- Is Michele Anderson a sociopath or a psychopath?
- Is Joseph McEnroe a sociopath or a psychopath?
- Will Michele Anderson ever feel guilt for her actions?
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Sanders, Paul. Banquet of Consequences: A Juror’s Plight: The Carnation Murders Trial of Michele Anderson. Vol. 3, Amazon Kindle, 2017.
Singer, Natalie. “Carnation Slayings Defendant Says She Wants to Be Executed.” The Seattle Times, The Seattle Times Company, 27 June 2008, www.seattletimes.com/seattle-news/carnation-slayings-defendant-says-she-wants-to-be-executed/.
Singer, Natalie. “Court Papers Tell of Victims’ Terrifying Last Moments.” The Seattle Times, The Seattle Times Company, 28 Dec. 2007, www.seattletimes.com/seattle-news/court-papers-tell-of-victims-terrifying-last-moments/.
Unknown, Unknown. “2007 Carnation Murders.” Wikipedia, Wikimedia Foundation, 30 June 2020, en.wikipedia.org/wiki/2007_Carnation_murders.
Washington Court of Appeals, From. “State Of Washington v. Michele Kristen Anderson.” Court of Appeals of Washington, CourtListener, 19 Feb. 2019, www.courtlistener.com/opinion/4591801/state-of-washington-v-michele-kristen-anderson/.
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